Labeling secondary containers in the workplace
“Do we have to label secondary containers?” That’s a common question regarding the requirements of the hazard communication, or HazCom, standard, so if you’ve ever wondered about that, you’re not alone.
And the answer is… It depends
The HazCom standard says, in part, “the employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer.”
The regulations define “immediate use” to mean that “the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred.”
So if the situation is such that the definition of immediate use is met, no label is needed. If this isn’t the case, however, you’ll need to label the container.
What kind of labeling is needed?
All workplace HazCom labels must include the product identifier and general information regarding all of the hazards of the chemical(s) even when using the NFPA or HMIS® system. In some cases, all hazards are not addressed by a particular rating system (e.g., chronic health hazards), and therefore, hazards not addressed must be communicated by words, pictures, symbols, or a combination thereof in addition to the NFPA or HMIS® rating system.
The HazCom regulations provide a few workplace labeling options. You can use:
- The elements required under HazCom on shipped containers, with the exception of contact information — product identifier, signal word, hazard statement(s), pictogram(s), and precautionary statement(s).
- In-house labels that include the product identifier and words, pictures, symbols, or a combination of these, which provide at least general information regarding the hazards of the chemicals.
- The HMIS® III or NFPA system.
Regardless of the workplace labeling option you use for secondary containers, you must ensure that your training program instructs employees on how to use and understand the labeling systems.
Keep in mind that the purpose of a label under HazCom is to serve as an immediate visual warning of the hazards associated with the chemical. The identity of the chemical leads to the more detailed information on the safety data sheet (SDS), but the hazard warning gives immediate information to employees working with the substance about the hazards associated with exposure.
Key to remember: A label is needed for secondary containers if the definition of “immediate use” is not met. “Immediate use” means that “the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred.”